Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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ITAT adjudicated multiple tax-related issues, ultimately ruling in favor of the assessee. The tribunal rejected the AO's disallowance of speculation loss, finding no regulatory requirement for off-market transaction reporting. Regarding gift taxation, ITAT upheld the assessee's claim that a father from a HUF can be considered a relative under Section 56(2). Additionally, for the trust-related income, ITAT determined that since the trust had already paid taxes on the transferred amount, further addition was unwarranted. Consequently, the tribunal set aside the AO and CIT(A) orders, directing deletion of all contested additions.
ITAT adjudicated multiple tax-related issues, ultimately ruling in favor of the assessee. The tribunal rejected the AO's disallowance of speculation loss, finding no regulatory requirement for off-market transaction reporting. Regarding gift taxation, ITAT upheld the assessee's claim that a father from a HUF can be considered a relative under Section 56(2). Additionally, for the trust-related income, ITAT determined that since the trust had already paid taxes on the transferred amount, further addition was unwarranted. Consequently, the tribunal set aside the AO and CIT(A) orders, directing deletion of all contested additions.
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